STIPULATED REQUEST AND [PROPOSED] ORDER TO EXTEND TIME FOR COUNTERCLAIM DEFENDANT SARATH BOYAPATI TO RESPOND TO COUNTERCLAIMS

WHEREAS on February 20, 2007, Defendants Bitech International LLC, Teledata Informatics Ltd., Anush Ramachandran, and AlphaSoft Services Corporation (collectively "Counterclaimants") filed their Counterclaims for violation of federal and state securities laws, and other claims for relief ("Counterclaims");

WHEREAS Plaintiff Sarath Boyapati ("Counterclaim Defendant Boyapati") has been served with the Counterclaims and has requested a seven day extension of time to respond to the Counterclaims;

WHEREAS this extension comports with Local Rule 6-1(a) because extending time for Counterclaim Defendant Boyapati to respond to the Counterclaims does not alter the date of any deadline already fixed by Court order;

WHEREAS counsel for Counterclaimants has agreed to the extension;

NOW THEREFORE, the parties stipulate as follows:

Counterclaim Defendant Boyapati's response to the Counterclaims shall be filed and served on or before March 19, 2007.

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